Title
City of Manila vs. Gambe
Case
G.R. No. 1922
Decision Date
Mar 31, 1906
Pilot Francisco Gambe held solely liable for bridge damage caused by incorrect orders; lack of communication equipment deemed irrelevant to accident causation.
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Case Digest (G.R. No. 1922)

Facts:

  1. Parties Involved:

    • Plaintiff and Appellee: The City of Manila.
    • Defendant and Appellant: Francisco Gambe, the pilot in command of the steamer Alfred.
  2. Incident:

    • The steamer Alfred, under the command of Francisco Gambe, was involved in an accident that caused damage to a bridge.
  3. Defendant's Role:

    • Francisco Gambe, as the pilot, had complete control of the steamer Alfred at the time of the accident.
  4. Contention of the Defendant:

    • It was argued that the owners of the steamer Alfred should be held responsible for the damages because the vessel was not equipped with modern communication tools, such as a speaking tube, between the bridge and the engine room.
  5. Evidence Presented:

    • The testimony of Major Case, the city engineer of Manila, and A. W. Ayres, inspector of the port, was presented to establish the actual damages suffered by the bridge.
    • No rebuttal evidence was introduced by the defense.
  6. Trial Court's Findings:

    • The trial court found that the accident was solely the result of the pilot's mistake in giving incorrect orders ("forward" and "full speed forward" instead of "astern" or "full speed astern").
    • The lack of a speaking tube was deemed irrelevant to the cause of the accident.

Issue:

  • (Unlock)

Ruling:

  • (Unlock)

Ratio:

  1. Pilot's Responsibility: A pilot in command of a vessel is personally responsible for damages resulting from their negligence or mistakes while in control of the vessel.
  2. Causation: The lack of modern communication equipment (e.g., a speaking tube) does not absolve the pilot of responsibility if the accident was caused by their direct actions or errors.
  3. Burden of Proof: The plaintiff's evidence, if uncontroverted, is sufficient to establish the extent of damages, and the defense must present rebuttal evidence to challenge such findings.


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